1. Purpose
Eltham Dental Practice aims to meet the requirements of the Data Protection Act 2018, the United Kingdom General Data Protection Regulation (UK GDPR), the guidelines on the Information Commissioner’s (ICO) website, and our professional guidelines and requirements.

This privacy notice describes the type of personal information we hold, why we keep it, and what we do with it.

2. Registered name
The data controller is Rumit Desai.

3. Contact details
If you have an enquiry or request, please contact the practice manager:

Eltham Dental Practice
78 Dunvegan Road
Email: [email protected]
Phone: 0208 850 8886

This privacy notice is also available on the practice website, or a hard copy can be requested from the Practice by emailing or calling directly.

4. What information we collect, use, and why
The personal data we process includes:

• Name
• Address
• Contact details
• Gender
• Pronoun preferences
• Date of birth
• Nationality
• NHS number
• Medical history
• Dental history
• Family medical history
• Family contact details
• Emergency contact details
• Marital status
• Information about care needs
• Financial details
• Doctor’s details
• Treatment plans
• Consent
• X-rays
• Clinical photographs
• Digital scans
• Study models
• Appointment dates
• Details of complaints
• Call recordings

We may also process more sensitive special category data, including:

• Ethnicity
• Race
• Religion
• Health records
• Sex life information
• Sexual orientation

The reasons we process the data include:

• To fulfil our contract with you
• To maintain a contemporaneous clinical record
• To discuss treatment options
• To provide dental prevention and oral health advice
• To ensure any medication we prescribe is suitable
• To modify treatments based on individual needs
• To meet our obligations under the Equality Act 2010
• To carry out financial transactions
• To manage appointments, recall arrangements and send reminders
• To communicate with your next of kin in an emergency
• To communicate with parents or carers about the person being cared for
• To refer to other dentists, doctors and health professionals as required
• For debt recovery
• To continually improve the care and service you receive from us
• To assist with safeguarding or public protection concerns
• To assist with dealing with queries, complaints or claims

5. Lawful basis (Personal data)
Our lawful bases for processing personal data:

• A legitimate interest to provide evidence-based dental care to patients safely and effectively
• Consent of the data subject
• To comply with our legal obligations

6. Lawful basis (Special category data)
Our Article 9 conditions for processing special category data:

• Processing is necessary for ethical and professional health care purposes
• Processing is necessary to monitor and assess the quality of opportunity or treatment between different groups
• Consent of the data subject

7. Data protection rights
You have the following personal data rights:

• The right of access – you can ask for a copy of the data we hold about you. We do not usually charge you for copies of your information; if we charge you, we will explain why
• The right to rectification – you can ask us to correct or delete information if it is inaccurate or incomplete. If we have disclosed that information to a third party, we will let them know about the change
• The right to erasure – you can ask us to delete your personal data. For legal reasons, we may be unable to erase certain information (for example, information about your dental treatment). However, we can, if you ask us to, delete some contact details and other non-clinical information
• The right to restrict processing – you can ask us to limit how we use your personal data. For example, stop sending you appointment reminders or information about our service
• The right to data portability – you can ask us to transfer your personal data to someone else. For example, supplying your information electronically to another dentist
• The right to withdraw consent – you can withdraw your consent to the processing of your personal data at any time. For example, even if you have given us consent to send you marketing information, you may withdraw that consent

8. Where we get personal information from
We obtain your details when you enquire about our care and service, when you join the practice, when you subscribe to our newsletter or register online, when you complete a registration or medical history form, from family members or carers, and when another healthcare provider refers you for treatment at our practice.

9. How long we keep information
We minimise the data that we keep, and do not keep it for longer than necessary.

We keep your records for 11 years after the date of your last visit to the Practice or until you reach the age of 25, whichever is longer. At your request, we will delete non-essential information (for example, some contact details) before the end of this period.

10. How we store information
We store your personal information securely on our practice computer system. Only those working at the practice have access to your information. They understand their legal responsibility to maintain confidentiality and follow practice procedures to ensure this.

We take precautions to ensure the security of the practice premises, the practice filing systems and computers.

We use high-quality specialist dental software to record and use your personal information safely and effectively. Our computer system has a secure audit trail, and we back up information routinely.

11. Sharing information
To provide you with appropriate care, we might need to share personal data with the following; however, only the minimum information required will be shared:

• Another dentist or another health professional who is caring for you
• Your GP or consultant
• A laboratory
• NHS payment authorities
• The Inland Revenue
• The Benefits Agency, if you are claiming exemption or remission from NHS charges
• A private dental scheme, if you are a member
• Safeguarding organisations

12. Duty of confidentiality
Exceptional circumstances might override the duty to maintain confidentiality. We will inform you of requests to share personal information where possible. The decision to disclose information will only be taken by senior staff. Examples include:

• Situations where there is a serious public health risk or risk of harm to other individuals
• When information is required by the police to prevent or detect crime or to apprehend or prosecute offenders (if not providing the information would prejudice these purposes)
• In response to a court order
• To enable a dentist to pursue a legal claim against a patient

13. National data opt-out
Whenever you use a health or care service, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you can also be used and provided to other organisations for purposes beyond your care, for instance, to help with:

• Improving the quality and standards of care provided
• Research into the development of new treatments
• Preventing illness and diseases
• Monitoring safety
• Planning services

This may only occur when there is a clear legal basis for using this information. All these uses help to provide better health and care for you, your family and future generations.

If you are happy with this use of information, you do not need to do anything. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. If you choose to opt out, your confidential patient information will still be used to support your care.

14. How to complain
If you have any comments, suggestions, or complaints about how we use your data, you can contact us using the contact details at the top of this privacy notice.

If you remain unhappy with our response or feel unable to discuss it with the Practice, you can contact the Information Commissioner’s Office (ICO) on 0303 123 1113 or by visiting https://www.ico.org.uk/make-a-complaint.

15. Review and Revision
This privacy notice is reviewed annually and updated to ensure its effectiveness and compliance with current regulations, guidance, and standards.